The Regulation of Safety, Security and Safeguards in UK. Mark Bassett HM Deputy Chief Inspector Office for Nuclear Regulation. Contents. Office for Nuclear Regulation Legislative and Regulatory Framework Joined-up Regulation Some Thoughts.
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HM Deputy Chief InspectorOffice for Nuclear Regulation
ONR Mission: Secure the protection of people and society from the hazards of the nuclear industry
We regulate safety, security, radioactive materials transport and have responsibilities for safeguards
Currently an agency of Health and Safety Executive
The Energy Bill is currently going through Parliament for ONR to become an independent public corporation
Target for “vesting” April 2014Office for Nuclear Regulation
Safety from the hazards of the nuclear industry
Health and Safety at Work Act 1974
General duty on all employers to reduce risks So Far As Is Reasonably Practicable (SFAIRP) – often known as ALARP
Dutyholders should identify and implement reasonably practicable measures to improve health and safety
HSWA enables number of regulations e.g. Ionising Radiations Regulations – sometimes more prescriptive
Nuclear Installations Act 1965 Relevant SectionsLegislative and Regulatory Framework
Prescribed Installations – Licensed
36 Standard Licence Conditions – shall make and implement adequate arrangements
e.g. LC14 production and assessment of safety
LC23 safety case to set limits and conditions
LC11 Emergency arrangements.
Permissioning Regime – e.g. Consents and Approvals
Inspectors appointed under S19 of HSWA and powers e.g. S20 plus enforcement powers
Internal guidance to our inspectors – Safety Assessment Principles
Security - continued
Secretary of State sets the “risk appetite”
ONR developed National Objectives, Requirements and Model Standards (NORMS)
Sets Objectives and Requirements – and recommends model standards (or adopt others that demonstrate meet the objectives)
Design Basis Threat – Nuclear Industry Malicious Capability Planning Assumptions
ONR formally approves Nuclear Site Security Plan (NSSP) - compromises a security case and an integrated protection solution (IPS)
ONR inspects against the plan
Security - continued
NSSPs in process of being written by dutyholders.All Cat 1 sites to have approved plans by November this year. Lower category sites by August
Security was more prescriptive than safety but NORMS part of the journey towards more goal-setting approach
Inspectors appointed under S19 HSWA – S20 powers as applied by regulation in NISR – some sections of the IRRs
HSWA S2 and 3 don’t apply e.g. SFAIRP But where appropriate we consider “as secure as reasonably practicable”
Materials Consolidation – Dounreay to Sellafield (one project integrating safety, security, transport, safeguards) “one-stop shop”
Generic Design Assessment and New Build (Safety/Security – safeguards piggy-backing)
Emergency Arrangements – joint safety and security exercises
Security enhancements – potential conflict between security and hazard reduction. What’s the overall holistic solution?
Joined-Up inspection with Euratom on new Pu stores prior to permissioning operations.
Linkage/leverage with licensees – multi-level messaging
Reporting and OPEX
Some Thoughts from the hazards of the nuclear industry
It’s still a journey – More to do and want to learn from others
Main barriers are cultural and our thinking – not legal structures etc.
Need for overall safety/security/safeguards culture
Think 3S – Mutual awareness and understanding